Background
Naasson Hazzard was convicted of kidnapping resulting in death and sentenced to life in prison under Section twelve hundred one of Title eighteen of the United States Code. He appealed, arguing insufficient evidence, a violation of his constitutional speedy trial rights, and that Congress exceeded its authority under the Commerce Clause.
The court’s reasoning
The court held that a rational juror could find the defendant kidnapped the victim to kill her and that the victim was held against her will. Regarding the speedy trial claim, the court noted the trial occurred within five months of the complaint, precluding a finding of error. On the Commerce Clause issue, the court cited precedent establishing that federal jurisdiction exists when the offender uses instrumentalities of interstate commerce, even for intrastate activities.
What it means going forward
The affirmation reinforces the Fifth Circuit’s stance on the sufficiency of evidence for kidnapping resulting in death and confirms the reach of federal jurisdiction over intrastate crimes involving interstate instrumentalities.
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